ABAKADA Guro Partylist v. Purisima | GR. No.

166715
FACTS: RA 9335, a tax reform legislation, was enacted to optimize the revenue-generation capability and
collection of the Bureau of Internal Revenue (BIR) and the Bureau of Customs (BOC). It is intended to
encourage BIR and BOC officials and employees to exceed their revenue targets by providing a system of
rewards and sanctions through the creation of a Rewards and Incentives Fund and a Revenue Performance
Evaluation Board. It covers all officials and employees of the BIR and the BOC with at least six months of
service, regardless of employment status. The Fund is sourced from the collection of the BIR and the BOC in
excess of their revenue targets for the year, as determined by the Development Budget and Coordinating
Committee (DBCC). Any incentive or reward is taken from the fund and allocated to the BIR and the BOC in
proportion to their contribution in the excess collection of the targeted amount of tax revenue.
Each Board has the duty to (1) prescribe the rules and guidelines for the allocation, distribution and release of
the Fund; (2) set criteria and procedures for removing from the service officials and employees whose revenue
collection falls short of the target; (3) terminate personnel in accordance with the criteria adopted by the Board;
(4) prescribe a system for performance evaluation; (5) perform other functions, including the issuance of rules
and regulations and (6) submit an annual report to Congress.
The DOF, DBM, NEDA, BIR, BOC and the Civil Service Commission (CSC) were tasked to promulgate and
issue the implementing rules and regulations of RA 9335, to be approved by a Joint Congressional Oversight
Committee created for such purpose.
Petitioners, invoking their right as taxpayers filed this petition challenging the constitutionality of RA 9335.
ISSUE: Whether or not there was an unduly delegation of power to fix revenue targets to the President.
RULING: No. To determine the validity of delegation of legislative power, it needs the following: (1) the
completeness test and (2) the sufficient standard test. A law is complete when it sets forth therein the policy to
be executed, carried out or implemented by the delegate. It lays down a sufficient standard when it provides
adequate guidelines or limitations in the law to map out the boundaries of the delegates authority and prevent
the delegation from running riot. To be sufficient, the standard must specify the limits of the delegates
authority, announce the legislative policy and identify the conditions under which it is to be implemented.
RA 9335 adequately states the policy and standards to guide the President infixing revenue targets and the
implementing agencies in carrying out the provisions of the law. The Fund is, hereby created, to be sourced
from the collection of the BIR and the BOC in excess of their respective revenue targets of the year, in a
percentage determined by the Development Budget and Coordinating Committee (DBCC) Thus, the
determination of revenue targets does not rest solely on the President as it also undergoes the scrutiny of the
DBCC.